CFTC: Brexit-Related Time Limited No-Action Position for Swap Dealers

ISDA requests that the Divisions maintain the status quo prior to Brexit by (i) allowing U.S. SDs to continue to treat the UK as one of the Six Jurisdictions for purposes of the Guidance Foreign Branch Treatment, and (ii) allowing registered SDs to rely on the staff letter 20-39 in lieu of the required comparability determination under the Limited Group B Exceptions